Comment from David Ludlum

Scientific research is documenting that the Delaware River has its own genetic line of Atlantic sturgeon – research shows that haplotype A5 is -unique to the Atlantic sturgeon of the Delaware River. Experts have estimated that the Delaware River population is very likely is less than 100. The current proposal to combine the Delaware River population, one of the lowest Atlantic sturgeon populations in the country, with the Hudson River population which is one of the largest Atlantic sturgeon populations left in the country, masks the highly precarious position of this ecologically, historically and culturally important species. The Delaware River population of Atlantic sturgeon suffer a wide array of threats and harms in the Delaware River, with more on the horizon – too many of which are going unaddressed, or not adequately addressed, in order to prevent or minimize their harms on the species. It is critical that the level of protection provided by “endangered” designation be afforded the Atlantic Sturgeon of the Delaware River. Because the Delaware River has a distinctly unique genetic line of Atlantic sturgeon whose counts are so low that extinction is absolutely foreseeable unless strong protections and actions are taken immediately, I urge you to identify the Delaware River population of Atlantic sturgeon as federally endangered either by granting “endangered” designation to the whole United States population of Atlantic Sturgeon or by identifying the Delaware River population as a Distinct Population Segment that is itself “endangered”. I look forward to receiving a response on how your organization plans to act to protect this ailing species from extinction.